FEVO Privacy Policy

This Privacy Policy describes the policies and procedures of FEVO, Inc. (“FEVO”, “we”, “our” or “us”) on the collection, use and disclosure of your information on www.fevo.com (the “Site”) and the services, features, content or applications we offer (collectively with the Site, the “Services”). When you use the Services, you are consenting to the collection, use, transfer, storage, disclosure and other uses of your information as described in this Privacy Policy.

This Privacy Policy covers the treatment of personal information gathered when you are using or accessing the Services. This Privacy Policy also covers our treatment of any personal information that our business partners share with us or that we share with our business partners. This Privacy Policy does not apply to the practices of third parties that we do not own or control, including but not limited to: any third-party websites, services and applications that you access through the Services, including websites of companies offering goods, services, events, or other offerings in partnership with Fevo  (“Offer Provider”). While we attempt to facilitate access only to those third-party services that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those third-party services. We encourage you to carefully review the privacy policies of any third-party services you access.

The information we gather enables us to personalize, improve, and operate the Services. In connection with certain aspects of the Services, we may request, collect, and/or display some of your personal information. We collect the following types of information from our users.

When you create an Account or purchase from us without creating an account, including via third-party websites or applications, such as Offer Provider website or applications, you will provide information such as your name, email address, phone number, address, payment information, and/or password. We may also ask for demographic information or other information relevant to the offer, event, or prizes that the Offer Provider may provide.

We collect personal information from you such as email address, phone number, or mailing address when you request information about our Services, register for our marketing communications or loyalty program, request customer or technical support, apply for a job, or otherwise communicate with us.

We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.

We may offer forums, blogs, or social media pages. Any content you provide on these channels will be considered “public” and is not subject to privacy protections.

We may run sweepstakes and contests. Contact information you provide may be used to reach you about the sweepstakes or contest and for other promotional, marketing and business purposes, if permitted by law. In some jurisdictions, we are required to publicly share personal information of winners.

‍User Content
‍Some features of the Services may allow you to provide content to the Services. All content submitted by you to the Services may be retained by us indefinitely, even after you terminate your account. We may continue to disclose such content to third parties in a manner that does not reveal personal information, as described below.

Location Information
Some of our Services may include features based on your actual locations and may report your current locations (“Location-Based Services”). To the extent you use any Location-Based Services, we will collect and store information about your location at the time you use those Location-Based Services. This information can come from a variety of sources depending on the client and device you use to access the Services; for example, a mobile phone may report its GPS location or IP address at the time Location-Based Services are used. You can opt out of Located-Based Services by changing the settings directly on your device.
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Financial Information
If you make purchases through the Services, your financial information, such as your payment method (valid credit card number, type, expiration date or other financial information), is collected and stored by our third-party payment processing company (the “Payment Processor"), and use and storage of that information is governed by the Payment Processor's applicable terms of service and privacy policy. We currently use Stripe as our Payment Processor (www.stripe.com). In order to facilitate your order transactions, we collect and store your billing zip code, credit card type and the last four digits of your credit card number, but no other financial information.

Shipping Information
We may collect your shipping information in connection with certain purchases through the Services. We may pass this information to our Payment Processor, Offer Providers, partners, and service providers for purposes of customer service, fulfillment, shipping and returns. The use of your personal information by such parties is subject to their respective privacy policies.

IP Address Information and Other Information Collected Automatically
We automatically receive and record information from your web browser or device when you interact with the Services, including your IP address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services. Information we collect may be associated with accounts and other devices.  

Generally, the Services automatically collect usage information, such as the number and frequency of visitors to the Site. We may use this data in aggregate form, that is, as a statistical measure, but not in a manner that would identify you personally. This type of aggregate data enables us and third parties authorized by us to figure out how often individuals use parts of the Services so that we can analyze and improve them.

We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us and our partners to record certain pieces of information whenever you visit or interact with our Services.

‍Cookies. 
Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.

‍Pixel Tags/Web Beacons. 
A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.

We may also use Google Analytics and other service providers to collect information regarding visitor behavior and visitor demographics on our Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.

‍Information from Other Sources
We may obtain information about you from other sources, including through third-party services and organizations to supplement information provided by you.
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If you access our Services through a third-party website or application, such as an Offer Provider, app store, a third-party login service, or a social networking site (such as Facebook), we may collect information about you from that third party. Information we collect through these services may include your name, your user identification number, your username, location, gender, birth date, email, profile picture, and your contacts stored in that service. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services.

We collect statistical information about how both unregistered and registered users, collectively, use the Services (“Aggregate Information”). Some of this information is derived from personal information. This statistical information is not personal information and cannot be tied back to you, your Account or your web browser.

We use your information for a variety of business purposes, including to:

Fulfil our contract with you and provide you with our Services, such as:
- Managing your information and accounts;
- Providing access to certain areas, functionalities, and features of our Services;Communicating with you about your account, activities on our Services and policy changes;
- Undertaking activities to verify or maintain the quality or safety of a service or device;
- Processing your financial information and other payment methods for products or Services purchased;
- Providing advertising, analytics and marketing services;
- Providing Services on behalf of our customers, such as maintaining or servicing accounts, providing customer service, and verifying customer information; 
- Processing applications and transactions; and
- Allowing you to register for offers.
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Analyze and improve our Services pursuant to our legitimate interest, such as:
- Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
- Measuring interest and engagement in our Services and short-term, transient use, such as contextual customization of ads;
- Undertaking research for technological development and demonstration;
- Researching and developing products, services, marketing or security procedures to improve their performance, resilience, reliability or efficiency;
- Improving, upgrading or enhancing our Services or device or those of our Providers;
- Developing new products and Services;Ensuring internal quality control;
- Verifying your identity and preventing fraud;
- Debugging to identify and repair errors that impair existing intended functionality;
- Enforcing our terms and policies; and
- Complying with our legal obligations, protecting your vital interest, or as may be required for the public good.
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Provide you with additional content and Services, such as:
- Furnishing you with customized materials about offers, products, and Services that may be of interest, including new content or Services;
- Auditing relating to interactions, transactions and other compliance activities; and
- Other purposes you consent to, are notified of, or are disclosed when you provide personal information.

We may use personal information and other data about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create.

Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services.

Our customers may choose to use our Services to process certain data of their own, which may contain personal information. The data that we process through our Services is processed by us on behalf of our customer, and our privacy practices will be governed by the contracts that we have in place with our customers, not this Privacy Policy.
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If you have any questions or concerns about how such data is handled or would like to exercise your rights, you should contact the person or entity (i.e., the data controller) who has contracted with us to use the Service to process this data. Our customers control the personal information in these cases and determine the security settings within the account, its access controls and credentials. We will, however, provide assistance to our customers to address any concerns you may have, in accordance with the terms of our contract with them. For a list of our sub-processors, contact us as described below.

We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies to automatically collect information through the Services. Our uses of these Technologies fall into the following general categories:
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‍Operationally Necessary.
This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
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‍Performance Related. 
We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;

‍Functionality Related. 
We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;

‍Advertising or Targeting Related. 
We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third party sites.

Your browsing activity may be tracked across different websites and different devices or apps. For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your laptop. To do this our technology partners may share data, such as your browsing patterns, geo-location and device identifiers, and will match the information of the browser and devices that appear to be used by the same person.

The Services may contain links to other websites, and other websites may reference or link to our website or other Services. These other websites are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

Our Services may include publicly accessible blogs, forums, social media pages, and private messaging features. By using such Services, you assume the risk that the personal information provided by you may be viewed and used by third parties for any number of purposes. In addition, social media buttons such as Facebook, Twitter, Instagram, and LinkedIn (that might include widgets such as the “share this” button or other interactive mini-programs) may be on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a third party or hosted directly on our site. Your interactions with these features apart from your visit to our site are governed by the privacy policy of the company providing it.
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We may use third party APIs and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties including analytics and advertising partners to collect your personal information for various purposes including to provide analytics services and content that is more relevant to you. For more information about our use of APIs and SDKs, please contact us as set forth below.

Certain of the Services are designed to help you share information with others. As a result, some of the information generated through the Services is shared publicly or with third parties. Except as provided below, we do not share your personal information.

Service Providers.
We may share any personal information we collect about you with our third-party service providers. The categories of service providers (processors) to whom we entrust personal information include: IT and related services; payment processors; customer service providers; and vendors to support the provision of the Services.
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Business Partners. 
We may provide personal information to business partners with whom we jointly offer products or services, including third-party websites and applications, such as Offer Providers. In such cases, our business partner’s name will appear along with ours.

Affiliates. 
We may share personal information with our affiliated companies.

Advertising Partners. 
Through our Services, we may allow third party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information (such as demographic information and past purchase history) with third party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your personal information with third party advertising partners, you may follow the instructions below.

Disclosures to Protect Us or Others. 
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

Disclosure in the Event of Merger, Sale, or Other Asset Transfers. 
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

International Data Transfers. 
You agree that all information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. Further details can be provided upon request.

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.

By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.

You have certain choices about your personal information.
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You can use some of the features of the Services without registering, thereby limiting the type of information that we collect. You can always opt not to disclose certain information to us, even though it may be needed to take advantage of some of our features.
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Account Deactivation. 
Should you ever decide to deactivate your Account, you may do so by emailing support@fevo.com or otherwise through the Services. If you deactivate your Account, any association between your Account and information we store will no longer be accessible through your Account. However, given the nature of sharing on the Services, any public activity on your Account prior to deactivation will remain stored on our servers and will remain accessible to the public in accordance with applicable law.
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Email and Telephone Communications. 
If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to our Terms or this Privacy Policy). We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists as required by applicable law.
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“Do Not Track.” 
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
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Cookies and Interest-Based Advertising. 
You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/. To separately make choices for mobile apps on a mobile device, you can download DAA’s AppChoices application from your device’s app store. Alternatively, for some devices you may use your device’s platform controls in your settings to exercise choice. Please note you must separately opt out in each browser and on each device. Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.
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Your Privacy Rights
In accordance with applicable law, you may have the right to:

- Access to/Portability of Personal Data about you consistent with legal requirements. In addition, you may have the right in some cases to receive or have your electronic Personal Data transferred to another party.
- Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information or we may refer you to the controller of your personal information who is able to make the correction.
- Request Deletion of your personal information, including the right to opt in or opt out of the sale of your Personal Data to third parties, if applicable, where such requests are permitted by law.
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If you would like to exercise any of these rights, please log into your account or contact us as set forth below. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.

We store the personal information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information FEVO has collected about them and whether FEVO disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth above. 

‍“Sales” of Personal Information under the CCPA

‍For purposes of the CCPA, FEVO does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age. Additional Privacy Rights for California Residents

Non-Discrimination.
California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA. 

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth below.

‍Verification.
To protect your privacy, we will take steps the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include asking you to verify the email address associated with your FEVO account.If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth below. We will process such requests in accordance with applicable laws.

‍Accessibility.
This Privacy Policy uses industry-standard technologies and was developed in line with the World Wide Web Consortium’s Web Content Accessibility Guidelines, version 2.1. If you wish to print this policy, please do so from your web browser or by saving the page as a PDF. 

The Services are not directed to children under 17 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.

If you are located in the European Economic Area or the UK, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

We may amend this Privacy Policy from time to time. If we make material changes in the way we collect or use information, we will notify you by posting an announcement on the Services or sending you an email.

If you have any questions or concerns regarding privacy using the Services, please send us a detailed message to support@fevo.com. We will make every effort to resolve your concerns.

12 Little W. 12th Street
New York, NY 10014

Effective Date: October 2, 2020